August 1, 2014

To: U. S. Environmental Protection Agenc y
From: Jessie L. Carr. MPH Department of Environmental and Occupational Health, University of Pittsburgh jlcarr@pittedu
Re: Docket No. EPA-HQ-OAR-2013-0602 Clean Power Proposed Rule Public Hearing, Pittsburgh, PA

My name is Jessie Carr. I am a Research Scientist in the Department of Environmental and Occupational Health at the University of Pittsburgh, and I am grateful for the opportunity to voice my support for the proposed Clean Power Plan. Historically, common sense, health-based pollution control regulations have met concern over what they might cost, and we have seen again and again that the benefits far outweigh the costs.' From a public health perspective, the EPA's Proposed Rule is long overdue, and with projected near-term health benefits outweighing costs by 10 to 1, 2 we cannot afford to wait. Across the Commonwealth, we have some of the nations highest smog levels, 3 we are breaking heat wave records each summer, and more frequent and extreme storms and flooding threaten the livelihood and security of rural and urban residents alike. Implementing sensible carbon regulation can lessen the worst public health impacts of climate change, and support innovation and diversification in our energy sector. Carbon emission limits in the Proposed Rule are supported by 72% of Pennsylvania voters. 4 The Proposed Rule offers States flexibility to decide how they meet carbon standards, and I focus my comments on actions for Federal and State lawmakers to ensure that benefits of the Proposed Rule are shared equally and sustainably.

US EPA. Benefits and Costs of the Clean Air Act. Available: http://www.epa.gov/cleanairactbenefits/ 2 US EPA. Fact Sheet: Clean Power Plan. Available: http://www2.epa.govicarbon

pollution

- standards/fact-sheet-clean-power-plan 3 American Lung Association. (2014). State of the Air. Available: http://www.stateoftheair.org/ 4 Hopey D. (2014, June). Pennsylvania voters favor EPA greenhouse gas curbs, poll shows. Pittsburgh Post-Gazette. Available: http://www.post-gazette.cominews/politicsstate/ 2014 / 06 / 05 /Pennsylvania-voters-favor-EPA-greenhouse-gas-curbs-polisshow/stories/201406050309. Poll summary available from the League of Conservation Voters: http://www.lcv.org/issues/polling/pa-poll-on-carbon-rules-and.pdfFirst, the EPA must require environmental justice analysis as part of State

Implementation Plans (SIP) to ensure that communities already over-burdened with industrial pollution do not continue to disproportionately bear the costs, particularly for States that opt for cap-and-trade approaches. Second, without sensible, health-based regulations for the unconventional natural gas industry, the economic and health benefits of the Proposed Rule will be undone, and create potentially equally daunting challenges for future Pennsylvanians. Specifically, the EPA and DEP should require:
1. Best available technology for capturing unintended methane emissions, green completions, and closed-loop waste-water systems; 2. Monitoring of well bore integrity: 3. Health-protective well permitting guidelines; 4. Enforcement authority and resources for state and local agencies; 5. Transparency around produced water components and disposal; and 6. Prospective epidemiological investigations of potential health impacts.

Thank you.